Abstract. This paper extends a turbulence closure-like model for stably stratified flows into a new dynamic domain in which turbulence is generated by internal gravity waves rather than mean shear. The model turbulent kinetic energy (TKE, K) balance, its first equation, incorporates a term for the energy transfer from internal waves to turbulence. This energy source is in addition to the traditional shear production. The second variable of the new two-equation model is the turbulent enstrophy ( ). Compared to the traditional shear-only case, the -equation is modified to account for the effect of the waves on the turbulence time and space scales. This modification is based on the assumption of a non-zero constant flux Richardson number in the limit of vanishing mean shear when turbulence is produced exclusively by internal waves. This paper is part 1 of a continuing theoretical development. It accounts for mean shear-and internal wavedriven mixing only in the two limits of mean shear and no waves and waves but no mean shear, respectively.The new model reproduces the wave-turbulence transition analyzed by D' Asaro and Lien (2000b). At small energy density E of the internal wave field, the turbulent dissipation rate (ε) scales like ε∼E 2 . This is what is observed in the deep sea. With increasing E, after the wave-turbulence transition has been passed, the scaling changes to ε∼E 1 . This is observed, for example, in the highly energetic tidal flow near a sill in Knight Inlet. The new model further exhibits a turbulent length scale proportional to the Ozmidov scale, as observed in the ocean, and predicts the ratio between the turbulent Thorpe and Ozmidov length scales well within the range observed in the ocean.